Personal Data Processing Policy

1. General Provisions.
This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ "On Personal Data" of 27 July 2006 (hereinafter, the "Personal Data Law") and sets out the procedure for processing personal data and the measures taken to ensure the security of personal data by Ekaterina Vyacheslavovna Anuchina (hereinafter, the "Operator").

1.1. The Operator's foremost objective and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy and to personal and family confidentiality.

1.2. This Operator's Policy on the processing of personal data (hereinafter, the "Policy") applies to all information that the Operator may obtain about visitors to the website it-seo.com/en.

2. Key Terms Used in this Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to rectify the personal data).

2.3. Website means the set of graphic and informational materials, as well as computer programs and databases, that make them available on the internet at the network address it-seo.com/en.

2.4. Personal data information system means the set of personal data contained in databases and the information technologies and technical means that ensure their processing.

2.5. Depersonalization of personal data means actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belong to a specific User or other data subject.

2.6. Processing of personal data means any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, rectification (updating, alteration), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state body, municipal body, legal entity or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website it-seo.com/en.

2.9. Personal data authorized by the data subject for dissemination means personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data authorized for dissemination in the manner prescribed by the Personal Data Law (hereinafter, "personal data authorized for dissemination").

2.10. User means any visitor to the website it-seo.com/en.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including publication of personal data in the mass media, posting on information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data are irreversibly destroyed, making it impossible to restore the content of the personal data in the personal data information system, and/or as a result of which the physical media containing personal data are destroyed.

3. Principal Rights and Obligations of the Operator

3.1. The Operator has the right to:
– receive accurate information and/or documents containing personal data from the data subject;
– where the data subject withdraws consent to the processing of personal data or submits a request to stop processing personal data, continue processing the personal data without the data subject's consent if there are grounds for doing so set out in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to fulfil the obligations set out in the Personal Data Law and the regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
– provide the data subject, at their request, with information regarding the processing of their personal data;
– organize the processing of personal data in the manner established by the applicable legislation of the Russian Federation;
– respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– provide the authorized body for the protection of the rights of data subjects, at its request, with the necessary information within 10 days of receiving such a request;
– publish or otherwise ensure unrestricted access to this Policy on the processing of personal data;
– take legal, organizational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, or dissemination, as well as against other unlawful actions in relation to personal data;
– stop the transfer (dissemination, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
– perform other obligations provided for by the Personal Data Law.

4. Principal Rights and Obligations of Data Subjects

4.1. Data subjects have the right to:
– receive information regarding the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the data subject by the Operator in an accessible form and shall not contain personal data relating to other data subjects, except where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
– require the Operator to rectify, block or destroy their personal data if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
– make prior consent a condition for the processing of personal data for the purpose of promoting goods, works and services on the market;
– withdraw consent to the processing of personal data and submit a request to stop the processing of personal data;
– appeal against unlawful actions or omissions of the Operator in processing their personal data to the authorized body for the protection of the rights of data subjects or in court;
– exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data subjects are obliged to:
– provide the Operator with accurate information about themselves;
– notify the Operator of any rectification (updating, alteration) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another data subject without the latter's consent, shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. Personal data are processed on a lawful and fair basis.

5.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes for which the data were collected is not permitted.

5.3. Combining databases containing personal data processed for mutually incompatible purposes is not permitted.

5.4. Only personal data that meet the purposes of their processing are subject to processing.

5.5. The content and scope of the personal data processed correspond to the stated purposes of processing. Processing of personal data that is excessive in relation to the stated purposes is not permitted.

5.6. When processing personal data, the accuracy and sufficiency of the personal data and, where necessary, their relevance to the purposes of processing are ensured. The Operator takes, or ensures that others take, the necessary measures to delete or rectify incomplete or inaccurate data.

5.7. Personal data are stored in a form that allows the data subject to be identified for no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor. Processed personal data are destroyed or depersonalized once the purposes of processing have been achieved or where achieving those purposes is no longer necessary, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing
Purpose of processing:
– informing the User by sending emails.
Personal data:
– last name, first name, patronymic;
– email address;
– telephone numbers.
Legal basis:
– contracts concluded between the Operator and the data subject.
Types of processing:
– collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data;
– sending informational emails to the email address.

7. Conditions for Processing Personal Data

7.1. Personal data are processed with the consent of the data subject to the processing of their personal data.

7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, and to perform the functions, powers and duties imposed on the Operator by the legislation of the Russian Federation.

7.3. The processing of personal data is necessary for the administration of justice or the enforcement of a judicial act or an act of another body or official that is subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary or guarantor, as well as for entering into a contract at the data subject's initiative or a contract under which the data subject will be a beneficiary or guarantor.

7.5. The processing of personal data is necessary for exercising the rights and legitimate interests of the Operator or third parties, or for achieving socially significant purposes, provided that the rights and freedoms of the data subject are not violated.

7.6. Personal data are processed to which the data subject has granted access to an unlimited number of persons, or which have been made accessible at the data subject's request (hereinafter, "publicly available personal data").

7.7. Personal data are processed that are subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for the Collection, Storage, Transfer and Other Processing of Personal Data
The security of personal data processed by the Operator is ensured through the implementation of the legal, organizational and technical measures required to fully comply with the applicable legislation on personal data protection.

8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable law or where the data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil law contract.

8.3. If any inaccuracies are found in the personal data, the User may update them independently by sending a notice to the Operator at the Operator's email address connect@it-seo.com marked "Updating personal data".

8.4. The period of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by a contract or applicable law.
The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator by email at connect@it-seo.com marked "Withdrawal of consent to personal data processing".

8.5. Personal data collected by third-party services, including payment processors, communication providers, and other service providers, is processed and stored in accordance with applicable laws and the respective providers' terms of service and privacy policies. Data subjects are encouraged to review these documents. The responsibilities of the Operator and third-party service providers regarding the processing and protection of personal data are determined by applicable law and the terms of their respective agreements.

8.6. Prohibitions imposed by the data subject on the transfer (other than providing access to), as well as on the processing or conditions of processing (other than obtaining access to), personal data authorized for dissemination do not apply where personal data are processed in the state, public or other public interests defined by the legislation of the Russian Federation.

8.7. When processing personal data, the Operator ensures the confidentiality of personal data.

8.8. The Operator stores personal data in a form that allows the data subject to be identified for no longer than required by the purposes of processing, unless the storage period is established by federal law or by a contract to which the data subject is a party, beneficiary or guarantor.

8.9. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing, the expiry of the data subject's consent, the withdrawal of consent by the data subject or a request to stop processing personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Personal Data Received

9.1. The Operator collects, records, systematizes, accumulates, stores, rectifies (updates, alters), retrieves, uses, transfers (disseminates, provides, grants access to), depersonalizes, blocks, deletes and destroys personal data.

9.2. The Operator carries out automated processing of personal data, with or without the receipt and/or transmission of the information obtained via information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing any cross-border transfer of personal data, the Operator is obliged to notify the authorized body for the protection of the rights of data subjects of its intention to carry out cross-border transfers of personal data (such notice is sent separately from the notice of intention to process personal data).

10.2. Before submitting the above notice, the Operator is obliged to obtain the relevant information from the foreign state authorities, foreign individuals and foreign legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data
The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties or disseminate them without the consent of the data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain any clarifications on matters concerning the processing of their personal data by contacting the Operator by email at connect@it-seo.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy remains in effect indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the internet at it-seo.com/en/privacy.